Detective measures
Lenzing takes complaints seriously and immediately initiates action once it becomes aware of potential negative impacts. Lenzing has established grievance mechanisms, with various internal reporting channels for employees. Additionally, an online tool is available for submitting concerns, accessible to all Lenzing Group employees, customers, suppliers, and others worldwide. The online tool is also accessible through the Lenzing website: Compliance – Lenzing – innovative by nature.
Whistleblower system
In order to enable all employees and other stakeholders to report concerns in connection with topics such as corruption, bribery, conflicts of interest, antitrust laws and capital market law, a global online-based whistleblower system is available since 2017. Lenzing`s joint venture LD Celulose also has its own whistleblower system. Grievances can be reported in-house in person, by phone or email, e.g. to supervisors, the works council or the Group Compliance Officer. In addition, the BKMS® whistleblower system (“Tell us”) is freely available via the Lenzing website to express any concerns anonymously (available in all languages relevant to production sites: English, German, Czech, Chinese, Bahasa, Thai and Portuguese). Reporting an incident not only relates to Lenzing’s employees, but also to customers, suppliers, and other third parties around the world. Concerns can be reported anonymously and without fear of retaliation worldwide thanks to this system, as the system’s anonymity protection function is certified by an independent body. The professional handling of the information protects both the whistleblower and the person affected.
Handling of reported concerns
Reports are processed in a targeted manner in accordance with the internal Investigation Directive (see the “Directives” (G1-1) section in this chapter). Reported incidents are assessed by lawyers (if necessary, in cooperation with local partners) and forwarded to the Group Compliance Officer or to the Local Compliance Officer. A report is processed by designated employees. The people entrusted with carrying out the procedure are obliged to maintain confidentiality. If necessary, other departments and people will also be involved in processing the incident if the circumstances require so. The reports are processed on a case-by-case basis, situation-related measures are defined and, if necessary, an investigation team is formed. This team includes employees and managers who are not involved in the incident itself. The confidentiality of the identity of the person concerned is maintained and the procedures provide effective protection from retaliation against the whistleblower (if the identity has been provided). Recommendations as to whether the investigation should be pursued further or terminated are provided. Monthly reporting on the status of compliance as well as ongoing investigations is provided to the Managing Board. In addition, the Audit Committee of the Supervisory Board is informed about the reported incidents on a quarterly basis.
Training is given to employees regarding the whistleblower system (Please see for recipients of the training the “Compliance training” section of this chapter.) Training is also given to those handling the reported concerns. The effectiveness, availability and overall acceptance of the whistleblower system are evaluated through an Integrity Survey. This survey is accompanied by a scientific team to ensure objectivity. 4,510 employees took part in the last Integrity Survey that was conducted in 2023.
If actual negative impacts on employees occur, remediation is provided on an individual basis as there is no Group-wide remediation process.
Training directive
All directives related to business conduct address the topic of training. A comprehensive Training Directive is being developed for assigning specific training sessions to designated job functions. In devising the directive, a risk assessment is conducted to create a more precise definition of the functions at risk and identify them within the organization. These identified functions are then subject to specialized training sessions. This approach ensures that employees are well equipped with the necessary knowledge and skills to perform their roles effectively and ethically, further enhancing Lenzing’s commitment to integrity and compliance. The Directive will become effective in the next fiscal year.